1. The goods involved in this case are "Castings in semi-finished condition for manufacture of Motor vehicles CKD Motor vehicle parts - Rear Axle housing (Iron castings)", as per the description given in the relevant Bill of Entry. The appellants are aggrieved of countervailing customs duty being charged on these goods under Item 25 of the Central Excise Tariff. This item covers, inter alia, "iron cast in any other shape or size". During the hearing before us today, the appellants maintained that the subject goods, after being cast, underwent further processes of annealing, straightening, buffing and rough machining and surface protection by metallic or non-metallic coatings in the foreign country before being shipped to India. They stated that after these processes, the goods ceased to be mere iron cast in any shape or size and became semi-finished articles which were not covered by Item 25 CET. Since there was no other one item of the CET converting such goods at the material time, the goods were free from countervailing duty. The Departments' representative stated that the further processes which the goods underwent in the foreign country were not such as would convert that